[January 7, 2011 Via Facsimile and EDGAR Assistant Director Division of Corporation Finance 100 F Street, N.E. Re: KongZhong Corporation Annual Report on Form 20-F for the Fiscal Year ended December 31, 2009 filed on June 4, 2010 (File No. 000-50826) Dear Mr. Spirgel: For your convenience, the Company has included the Staff’s comments in this response letter in italicized]
[January 7, 2011 Via Facsimile and EDGAR Assistant Director Division of Corporation Finance 100 F Street, N.E. Re: KongZhong Corporation Annual Report on Form 20-F for the Fiscal Year ended December 31, 2009 filed on June 4, 2010 (File No. 000-50826) Dear Mr. Spirgel: For your convenience, the Company has included the Staff’s comments in this response letter in italicized]
[Highpower International Appoints New CFO New York, NY and Shenzhen, China – January 3, 2011 – Highpower International, Inc. ( Nasdaq : HPJ) “We are pleased that Mr. Sun has joined our leadership team. He brings to Highpower significant experience in accounting, finance, operations, strategic planning, capital markets and investor relations,” said George Pan, Chief Executive Officer of Highpower International,] [Delaware 001-34098 20-4062622 (State or other jurisdiction of incorporation) (Commission File Number) (IRS Employer Identification No.) Building A1, Luoshan Industrial Zone, Shanxia, Pinghu, Longgang, Shenzhen, Guangdong, 518111, China (86) 755-89686238 (Former name or former address, if changed since last report.) ¨ ¨ ¨ ¨ Item 5.02 Departure of Directors of Certain Officers; Election of Directors; Appointment of Certain Officers; Compensatory]
[Highpower International Appoints New CFO New York, NY and Shenzhen, China – January 3, 2011 – Highpower International, Inc. ( Nasdaq : HPJ) “We are pleased that Mr. Sun has joined our leadership team. He brings to Highpower significant experience in accounting, finance, operations, strategic planning, capital markets and investor relations,” said George Pan, Chief Executive Officer of Highpower International,] [Delaware 001-34098 20-4062622 (State or other jurisdiction of incorporation) (Commission File Number) (IRS Employer Identification No.) Building A1, Luoshan Industrial Zone, Shanxia, Pinghu, Longgang, Shenzhen, Guangdong, 518111, China (86) 755-89686238 (Former name or former address, if changed since last report.) ¨ ¨ ¨ ¨ Item 5.02 Departure of Directors of Certain Officers; Election of Directors; Appointment of Certain Officers; Compensatory]
[FORM F-1 REGISTRATION STATEMENT ChinaCache International Holdings Ltd. Not Applicable Cayman Islands (State or other jurisdiction of 7389 (Primary Standard Industrial Not Applicable (I.R.S. Employer 6/F, Block A, Galaxy Plaza Law Debenture Corporate Services Inc. (Name, address, including zip code, and telephone number, including area code, of agent for service) Copies to: Z. Julie Gao, Esq. Approximate date of commencement] [DEPOSIT AGREEMENT DEPOSIT AGREEMENT W I T N E S S E T H T H A T : WHEREAS , the Company desires to establish with the Depositary an ADS facility to provide for the deposit of the Shares (as hereinafter defined) and the creation of American Depositary Shares representing the Shares so deposited; and WHEREAS , the Depositary] [Form of Legal Opinion Matter No.: 875271 Doc Ref: WL/ot/350838 (852) 2842 9532 wynne.lau@conyersdill.com ChinaCache International Holdings Ltd. 6/F, Block A, Galaxy Plaza No. 10 Jiuxianqiao Road Middle, Chaoyang District Beijing, 100015 Peoples Republic of China Dear Sirs, ChinaCache International Holdings Ltd. Re: Offering Shares Prospectus Registration Statement Securities Act Commission We have acted as special Cayman legal counsel to] [[LETTERHEAD OF SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP] Form of Legal Opinion ChinaCache International Holdings Ltd. 6/F, Block A, Galaxy Plaza No. 10 Jiuxianqiao Road Middle, Chaoyang District Beijing, 100015 The Peoples Republic of China American Depositary Shares of ChinaCache International Holdings Ltd. (the Company) Re: Ladies and Gentlemen: In connection with rendering the opinion set forth below, we] [PLACE OF Subsidiaries ChinaCache North America Inc. California, USA JNet Holdings Limited BVI ChinaCache Networks (Hong Kong) Limited Hong Kong ChinaCache Network Technology (Beijing) Limited PRC Variable Interest Entities] [Consent of Independent Registered Public Accounting Firm We consent to the reference to our firm under the caption Experts and to the use of our report dated May 19, 2010 in the Registration Statement (Form F-1) and the related Prospectus of ChinaCache International Holdings Ltd. for the registration of its ordinary shares. Shanghai, the Peoples Republic of China January 7,] [January 7, 2011 ChinaCache International Holdings Ltd. 6/F, Block A, Galaxy Plaza No. 10 Jiuxianqiao Road Middle, Chaoyang District Beijing, 100015 Peoples Republic of China Attention: Robert Yong Sha, Chief Financial Officer Dear Mr. Sha, iResearch Consulting Group Vice President EX-23.5 7 a2201551zex-23_5.htm EX-23.5] [January 6, 2011 ChinaCache International Holding Co., Ltd 6th Floor,Tower A,Galaxy Building No.10 Chaoyang Dirstrict, Beijing, P.R.China Postcode: 100016 Consent Letter Dear Sirs or Madams, We hereby consent to the references to our name, valuation methodologies, assumptions and value conclusions for your financial reporting purposes, with respect to our appraisal reports (the Reports) addressed to ChinaCache International Holdings Co., Ltd] [HAN KUN LAW OFFICES Room 906, Office Tower C1, Oriental Plaza, 1 East Chang An Avenue, Beijing 100738, P. R. China TEL: (86 10) 8525-5500; FAX: (86 10) 8525-5511/ 5522 [Form of Legal Opinion] To: ChinaCache International Holdings Ltd. Scotia Center, 4 th Floor, P.O. Box 2804, George Town, Cayman Islands, British West Indies Dear Sirs or Madams: PRC China]
[FORM F-1 REGISTRATION STATEMENT ChinaCache International Holdings Ltd. Not Applicable Cayman Islands (State or other jurisdiction of 7389 (Primary Standard Industrial Not Applicable (I.R.S. Employer 6/F, Block A, Galaxy Plaza Law Debenture Corporate Services Inc. (Name, address, including zip code, and telephone number, including area code, of agent for service) Copies to: Z. Julie Gao, Esq. Approximate date of commencement] [DEPOSIT AGREEMENT DEPOSIT AGREEMENT W I T N E S S E T H T H A T : WHEREAS , the Company desires to establish with the Depositary an ADS facility to provide for the deposit of the Shares (as hereinafter defined) and the creation of American Depositary Shares representing the Shares so deposited; and WHEREAS , the Depositary] [Form of Legal Opinion Matter No.: 875271 Doc Ref: WL/ot/350838 (852) 2842 9532 wynne.lau@conyersdill.com ChinaCache International Holdings Ltd. 6/F, Block A, Galaxy Plaza No. 10 Jiuxianqiao Road Middle, Chaoyang District Beijing, 100015 Peoples Republic of China Dear Sirs, ChinaCache International Holdings Ltd. Re: Offering Shares Prospectus Registration Statement Securities Act Commission We have acted as special Cayman legal counsel to] [[LETTERHEAD OF SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP] Form of Legal Opinion ChinaCache International Holdings Ltd. 6/F, Block A, Galaxy Plaza No. 10 Jiuxianqiao Road Middle, Chaoyang District Beijing, 100015 The Peoples Republic of China American Depositary Shares of ChinaCache International Holdings Ltd. (the Company) Re: Ladies and Gentlemen: In connection with rendering the opinion set forth below, we] [PLACE OF Subsidiaries ChinaCache North America Inc. California, USA JNet Holdings Limited BVI ChinaCache Networks (Hong Kong) Limited Hong Kong ChinaCache Network Technology (Beijing) Limited PRC Variable Interest Entities] [Consent of Independent Registered Public Accounting Firm We consent to the reference to our firm under the caption Experts and to the use of our report dated May 19, 2010 in the Registration Statement (Form F-1) and the related Prospectus of ChinaCache International Holdings Ltd. for the registration of its ordinary shares. Shanghai, the Peoples Republic of China January 7,] [January 7, 2011 ChinaCache International Holdings Ltd. 6/F, Block A, Galaxy Plaza No. 10 Jiuxianqiao Road Middle, Chaoyang District Beijing, 100015 Peoples Republic of China Attention: Robert Yong Sha, Chief Financial Officer Dear Mr. Sha, iResearch Consulting Group Vice President EX-23.5 7 a2201551zex-23_5.htm EX-23.5] [January 6, 2011 ChinaCache International Holding Co., Ltd 6th Floor,Tower A,Galaxy Building No.10 Chaoyang Dirstrict, Beijing, P.R.China Postcode: 100016 Consent Letter Dear Sirs or Madams, We hereby consent to the references to our name, valuation methodologies, assumptions and value conclusions for your financial reporting purposes, with respect to our appraisal reports (the Reports) addressed to ChinaCache International Holdings Co., Ltd] [HAN KUN LAW OFFICES Room 906, Office Tower C1, Oriental Plaza, 1 East Chang An Avenue, Beijing 100738, P. R. China TEL: (86 10) 8525-5500; FAX: (86 10) 8525-5511/ 5522 [Form of Legal Opinion] To: ChinaCache International Holdings Ltd. Scotia Center, 4 th Floor, P.O. Box 2804, George Town, Cayman Islands, British West Indies Dear Sirs or Madams: PRC China]
